NCS000101_email_20230928

Young, Brianna A
From: Young, Brianna A
Sent: Thursday, September 28, 2023 3:12 PM
To: Wallace H Coverdale
Cc: Colleen Cohn; Stephen Greer; Fail, Kimberly
Subject: RE: [External] Renewal, NPDES Stormwater Permit NCS000101
Good afternoon Wallace,
Please see below for responses to your questions.As I stated on the phone, as the permit renewal has been signed and
issued,the effective date cannot be changed. However,the Regional Office and Central Office can use discretion when
deciding on enforcement action(s) while any remaining questions are addressed.
1. The mill needs DEMLR to clarify oil and grease requirements for all outfalls. The attached e-mail from one
DEMLR source states that O&G sampling would be sampled only at outfalls that discharge stormwater from
VMA. Based on this guidance,the mill believes that the only outfall that may be subject to oil and grease
requirements is Outfall E,which has an oil/water separator through which any spill would pass. The other
DEMLR source stated that O&G may or may not be required, leaving room for interpretation. E is the
representative outfall for C, E, and A. Please note that both C and E contained chip dumps; the chip dump was
removed from C in 2023. Outfall A is included because of potential oil barge unloading;this has not happened
for nearly 10 years, because the mill has been retro-fitted to burn mostly natural gas. Please consider those
facts to resolve the conflicting guidance above.
General Permits and Individual Permits have different monitoring requirements.The initial email said Kimberly
Fail was asking about a General Permit, therefore she was directed to Brittany Cook, who provided an answer on
how General Permits are handled. Individual Permits require monitoring for O&G for all drainage areas that use
>55 gallons/month of oil on average per EPA Method 1664(SGT-HEM).This is why I stated monitoring may or
may not be required for VMA areas only and that permits should be read carefully and followed accordingly.
2. The Mill presented representative outfall status (ROS) renewal paperwork via Stormwater Upload portal, per the
permit cover letter. Brian Lambe of WiRO issued ROS guidance for the mill dated September 18, 2023. This
guidance restates his previous conclusions, which were based on his two site inspections earlier this year, and
documented in the mill's online Fact Sheet. The ROS plan includes Outfall M, like all previous permits,with
Outfall I as the representative sample point. This is in contradiction to the new permit requirement to exclude
Outfall M from the ROS program. Quantitative sampling has never been required for this outfall in previous
permits. The mill would like to restate that no methanol transport occurs in Basin M, and the methanol tank
and unloading area are completely contained. Also,the mill wants to clarify that the methanol tank is adjacent
to Basin M, not in it; any spill would flow toward the wastewater treatment system, not stormwater. The Mill
asked for Outfall M to be removed from the quantitative sampling list in its July 2023 comments letter on the
draft permit and was denied. If Outfall M must be added to the quantitative sampling list, please ensure the
eDMR template is updated by the time the next DMR needs to be submitted.
It's my understanding based on our phone call that you have addressed this question with the Regional Office.
3. The new permit cover letter dated September 7, 2023 states that"Tiered Response relief effectively ends at the
new permit cycle. Conditions start over at baseline monitoring, and permittees will have to seek relief again
if/when appropriate." The Mill would like to clarify that all outfalls will begin the new permit in Tier 1—no
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Tier. There is a reference on page 5 of the permit fact sheet that B and E were in Tier 2 during the previous
permit term;the Mill is assuming that DEMLR means that these two outfalls were in Tier 2 at some point during
the permit term but is unsure of the context of this sentence. The Mill would like to understand definitively
what the Tier starting point is for each outfall in the new permit.
Outfall status resets with the permit renewal (i.e. all outfalls drop back to no Tier status). However, if an outfall
was required to perform actions for Tier Response at the time of the permit renewal, then the appropriate Tier
Response actions will need to continue with the permit renewal. In other words,the number of counts towards
reaching Tiers 1, 2, and 3 reset at the permit renewal, but if,for example,the outfall required monthly
monitoring for Tier 3 response actions,then monthly monitoring must continue for the outfall until conditions
are met to drop out of Tier 3 response. You will need to review your monitoring data to determine any
appropriate Tier Response actions that are currently required. Please work with the Regional Office staff if you
need further assistance on this.
4. The mill needs to understand the new numbering requirements for outfalls. The mill hopes to minimize name
changes to prevent confusion for mill operations and contractors,who are well-trained in the original outfall
designations. Surely there is some way to incorporate existing names with new requirements. The eDMR is
currently set up with the original outfall designations and will require updating for consistent reporting.
eDMR transfers monitoring data to the EPA ECHO database. Unfortunately, issues occur in data transfer from
eDMR to ECHO when outfalls have alphabetical numbering,therefore, numerical numbering of the outfalls must
remain.The permit identifies each outfall with a numerical identification and the previous alphabetical
identification in parenthesis after it (e.g.:Table 1 lists SWO01 (Basin A), SW002, (Basin B), etc.). Hopefully this
dual identification will help reduce confusion on mill staff when taking and reporting samples. eDMR should
automatically update with your next submittal to reflect the new outfall naming scheme as the Stormwater
Program's internal database already reflects the new monitoring requirements.
5. If the Mill ends up being stuck with the additional sampling listed in Items 1, 2 and 3 of this e-mail,the Mill
would like to discuss options for sampling relief with DEMLR.
As stated in previous correspondence,you may request Representative Outfall Status (ROS). Based on our
phone call, it is my understanding that you have addressed this question with the Regional Office.
Please let me know if you have any other questions.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
919-707-3647 (office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address: 512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
2

Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: Wallace H Coverdale<[e-mail]>
Sent:Thursday,September 28, 2023 1:21 PM
To:Young, Brianna A<[e-mail]>
Cc: Colleen Cohn<[e-mail]>; Stephen Greer<[e-mail]>; Fail, Kimberly
<[e-mail]>
Subject: [External] Renewal, NPDES Stormwater Permit NCS000101
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Attached is a synopsis of items to be clarified or potentially revised in International Paper's new,final NPDES stormwater
permit,which goes into effect October 1, 2023. The items below need clarification so the mill will understand how to
comply with the new permit. Can the permit effective date be delayed until these items are understood? Thank you,
Wallace Coverdale
Wallace H Coverdale
Environmental Services Coordinator
[e-mail]
T 9103624590
M 9105126581
��
International
ww Paper
International Paper
865 John L. Riegel Rd
Riegelwood, NC 28456
internationalpaper.com
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NPDES NCS 000101—INTERNATIONAL PAPER
RESOLUTION TO FINAL RENEWAL QUESTIONS
September 28, 2023
1. The mill needs DEMLR to clarify oil and grease requirements for all outfalls. The attached e-mail
from one DEMLR source states that O&G sampling would be sampled only at outfalls that
discharge stormwater from VMA. Based on this guidance, the mill believes that the only outfall
that may be subject to oil and grease requirements is Outfall E, which has an oil/water separator
through which any spill would pass. The other DEMLR source stated that O&G may or may not
be required, leaving room for interpretation. E is the representative outfall for C, E, and A.
Please note that both C and E contained chip dumps;the chip dump was removed from C in
2023. Outfall A is included because of potential oil barge unloading;this has not happened for
nearly 10 years, because the mill has been retro-fitted to burn mostly natural gas. Please
consider those facts to resolve the conflicting guidance above.
2. The Mill presented representative outfall status (ROS) renewal paperwork via Stormwater
Upload portal, per the permit cover letter. Brian Lambe of WiRO issued ROS guidance for the
mill dated September 18, 2023. This guidance restates his previous conclusions, which were
based on his two site inspections earlier this year, and documented in the mill's online Fact
Sheet. The ROS plan includes Outfall M, like all previous permits,with Outfall I as the
representative sample point. This is in contradiction to the new permit requirement to exclude
Outfall M from the ROS program. Quantitative sampling has never been required for this outfall
in previous permits. The mill would like to restate that no methanol transport occurs in Basin
M, and the methanol tank and unloading area are completely contained. Also,the mill wants to
clarify that the methanol tank is adjacent to Basin M, not in it; any spill would flow toward the
wastewater treatment system, not stormwater. The Mill asked for Outfall M to be removed
from the quantitative sampling list in its July 2023 comments letter on the draft permit and was
denied. If Outfall M must be added to the quantitative sampling list, please ensure the eDMR
template is updated by the time the next DMR needs to be submitted.
3. The new permit cover letter dated September 7, 2023 states that "Tiered Response relief
effectively ends at the new permit cycle. Conditions start over at baseline monitoring, and
permittees will have to seek relief again if/when appropriate." The Mill would like to clarify that
all outfalls will begin the new permit in Tier 1—no Tier. There is a reference on page 5 of the
permit fact sheet that B and E were in Tier 2 during the previous permit term; the Mill is
assuming that DEMLR means that these two outfalls were in Tier 2 at some point during the
permit term but is unsure of the context of this sentence. The Mill would like to understand
definitively what the Tier starting point is for each outfall in the new permit.
4. The mill needs to understand the new numbering requirements for outfalls. The mill hopes to
minimize name changes to prevent confusion for mill operations and contractors, who are well-
trained in the original outfall designations. Surely there is some way to incorporate existing
names with new requirements. The eDMR is currently set up with the original outfall
designations and will require updating for consistent reporting.
5. If the Mill ends up being stuck with the additional sampling listed in Items 1, 2 and 3 of this e-
mail, the Mill would like to discuss options for sampling relief with DEMLR.

Wallace H Coverdale
From: Fail, Kimberly <[e-mail]>
Sent: Wednesday, September 13, 2023 12:39 PM
To: Wallace H Coverdale; Colleen Cohn; Stephen Greer
Subject: FW: [External] General industrial SW questions
All-
We can discuss this latest e-mail on our call this afternoon as well.
Wallace- Did you provide ROS information to Brian Lambe earlier in the year(maybe March 2023) prior to or during his
site inspection in March? He lists the representative outfalls in his March 2023 inspection report and recommends
permit issuance in that inspection report.
Talk to you soon,
Kim
From:Young, Brianna A<[e-mail]>
Sent:Wednesday, September 13, 2023 9:31 AM
To: Fail, Kimberly<[e-mail]>
Subject: RE: [External] General industrial SW questions
This is an External email. Dr not click links or open attachments unless you •- know the
content
hoverALWAYS over • • confirm
Good morning Kim,
For ROS requests, the Regional Office do handle these requests.There will be a site inspection and then the office will
handle any sort of notification to both to the permittee and Central Office.
Regarding your question on O&G, permittees must follow the requirements of their individual permit. Monitoring for
O&G may or may not be required from VMA areas only, so permittees should carefully read and follow their permit.
Please let me know if you have any other questions.
Thank you,
Brianna Young, MS (she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
[e-mail](e-mail preferred) PLEASE DOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different, but email performance will not be impacted.
919-707-3647 (office)
1

Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address:512 North Salisbury Street, Raleigh, NC 27604
Email correspondence to and from this address is subject to the North Carolina
Public Records Low and may be disclosed to third parties.
The Department of Environmental quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices,as we may be able to handle your requests by phone or email.
From: Fail, Kimberly<KFail trccompanies.com>
Sent:Wednesday, September 13, 2023 9:25 AM
To:Young, Brianna A<[e-mail]>
Subject: FW: [External] General industrial SW questions
CAUTION: External email. Do not click links or open attachments unless verified.Report suspicious emalls with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna—
Thanks for putting me in touch with Brittany. Just to cover my bases, I'm presuming that the answers to these two
questions would be the same for permit holders with individual (rather than general) permits?
Thanks again,
Kim
From: Cook, Brittany<[e-mail]>
Sent:Tuesday, September 12, 2023 1:39 PM
To: Fail, Kimberly<[e-mail]>
Subject: RE: [External] General industrial SW questions
contentThis is a n External ema il. Do not click links or open attachments u n less you validate the sender a nd know the
hoverALWAYS over • confirm
Hi Kimberly,
Thanks for reaching out.
1. The Regional Offices handle the bulk of ROS tasks and there's a chance each offices processes things a little
differently.That being said,the regional office should conduct a site visit and issue a formal approval/denial
letter.
2. You will only sample for O&G at outfalls that discharge Stormwater from VMA.
Please let me know if you have any other questions,
Mrs.Brittany Cook
NPDES Stormwater General Permit Coordinator
Stormwater Program,Division of Energy, Mineral,and Land Resources
N.C.Department of Environmental Quality
Phone: [phone]
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Email: [e-mail]
From:Young, Brianna A<[e-mail]>
Sent:Tuesday, September 12, 2023 11:23 AM
To: Fail, Kimberly<[e-mail]>
Cc: Cook, Brittany<Brittan .Cook de .nc. o,.•>
Subject: RE: [External] General industrial SW questions
Good morning Kimberly,
Please reach out to Brittany Cook as she is the Industrial General Permits Coordinator. 1 have copied her on this email.
Thank you,
Brianna Young, MS(she/her)
Industrial Individual Permits Coordinator
Stormwater Permitting Program
NC DEQ/Division of Energy, Mineral, and Land Resources (DEMLR)
Brianna.Youngndeq.nc.gov(e-mail preferred)PLEASE NOTE NEW EMAIL ADDRESS
**DEQ is updating its email addresses to @deq.nc.gov in phases from May 1st to June 9th. Employee email addresses may look
different but email performance will not be impacted.
919-707-3647(office)
Mailing address: 1612 Mail Service Center, Raleigh, NC 27699-1612
Physical address:512 North Salisbury Street, Raleigh, NC 27604
Emoil correspondence to and from this address is subject to the North Carolina
Public Records Law and may be disclosed to third parties.
The Department of Environmental Quality has adjusted operations to protect the health and safety of the staff and public. Please
check with the appropriate staff before visiting our offices, as we may be able to handle your requests by phone or email.
From: Fail, Kimberly<[e-mail]>
Sent:Tuesday,September 12, 2023 11:12 AM
To:Young, Brianna A<Brianna.Youn de .nc. ov>
Subject: [External] General industrial SW questions
CAUTION: External email. Do not click links or open attachments unless verified. Report suspicious emails with the Report Message
button located on your Outlook menu bar on the Home tab.
Brianna—
Hope your week is off to a good start! I had a few questions regarding general industrial SW permit forms and sampling
and thought you might be able to help.
1- Regarding the ROS Renewal certification form (https://www.deg.nc.gov/energy-mineral-and-land-
resources stormwater n P des- eneraI-permits ros-renewal-certification-form-2021-v3-fiIIable download), does
DEQ send permittees another formal approval upon receipt of this form and previous supporting approval
documentation? Or is this submittal just placed in the facility's DEMLR permit file?
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2- Regarding vehicle maintenance activities(VMAs) (https://www.deg.nc.gov/about/divisi_o_ns/energy-mineral-and-
land-resources stormwater stormwater- ro ram n des-industrial- ro ram technical- uidance#VMA), if VMAs
occur in just one drainage area at a facility, are all drainage areas required to sample for 0&G or just the
drainage area where the VMA is located?
Any help is greatly appreciated!
Thanks in advance,
Kim
Kimberly W. Fail, P.E. (SC, NC)
S,. Process Engineer/Project Manager
1429-116 Rock Quarry Road, Raleigh, NC 27610
TR C 828-405-3629 1 [e-mail]
"IrLinkedin Twitter TRCcomparies.com
Email correspondence to and from this address may be subject to the North Carolina Public Records Law and may be disclosed to third pasties by an authorized
state official.
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